If you read the February edition of The Background Buzz (see http://goo.gl/0iBHZ1) you likely saw the article, The Way Forward for Federal Background Investigations which discusses the U.S. Federal Government’s announcement of a series of changes to modernize and strengthen the way that background investigations are conducted for Federal employees and contractors and protect sensitive data. The changes include the establishment of the National Background Investigations Bureau (NBIB), which will absorb the U.S. Office of Personnel Management’s (OPM) existing Federal Investigative Services (FIS), and be headquartered in Washington, D.C. This new government-wide service provider for background investigations will be housed within the OPM. Its mission will be to provide effective, efficient, and secure background investigations for the Federal Government. Unlike the previous structure, the Department of Defense will assume the responsibility for the design, development, security, and operation of the background investigations IT systems for the NBIB. The article can be viewed at https://goo.gl/wIOe12

When I read about this the Criminal Records Bureau (CRB) which has morphed into the The Disclosure and Barring Service (DBS) in the United Kingdom instantly came to mind. In the UK the DBS is the governments entity that processes request for criminal records checks. While the announcement of the NBID is not the equivalent of the DBS, in my mind, it does not seem so far-fetched that based on the right (or wrong set of circumstances) occurring and unforeseen political events we could end up going down that road. Remember the set of unforeseen events that led to the creation of the NBIB due to the demise of USIS, who dominated the government space, as a result of accusations of fake reports, significant backlogs, missing key information in the background check of the shooter at the U.S. Naval yard and “the straw that broke the camel’s back” the humongous data breach at the OPM. It was a perfect storm of unanticipated events that coalesced and culminated in the creation of the NBIB.

I am raising a ‘What if?’ question regarding the NBIB and applying one of the principles of systems thinking’s ‘law of unintended consequences.’ The law of unintended consequences as defined by Businessdictionary.com is described as a set of results that was not intended [or anticipated] as an outcome or put another way as stated in an old saying “things do not always turn out as we expect.”

When I posted this same issue to Linkedin one person asked “What exactly was the issue I see the NBIB posing?” and I reiterate that I do not see NBIB in its current format significantly impacting the background screening industry. In fact, it will pose little, if any threat at all. However, the point I am raising is that it could be the first step in the direction of the government moving towards setting up a central repository for criminal records. This is not the reason the NBID has been set up nor do I think there is some clandestine plot to move in this direction, however, I am simply raising the possibility that another ‘political storm’ of unforeseen events could make it politically expedient to make the leap to combining the NBIB with the FBI’s NCIC and then you have the central repository. Its pure food for thought, but stranger things have happen.

W. Barry NIxon, SHRM-CMP is the founder of PreemploymentDirectory.com, the publisher of The Background Buzz, The Global Background Screener, The Annual Background Screening Industry Resource Guide and In Search of Excellence in Background Screening: Insights from Accredited Background Screening Firms. He is co-author of Background Investigations: Managing Hiring Risk from an HR and Security Perspective, a recognized background screening expert and serves as an International Ambassador for the National Association for Professional Background Screeners.